Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reopening of assessment u/s 147 - AO having not carried out the scrutiny assessment within the prescribed statutory limit, cannot be given another innings for no fault of the assessee and therefore in the facts and circumstances of the case, ‘reason to believe’ which is the jurisdictional precondition to reopen the assessment as required by the law has not been met in the reasons recorded in the instant case
Reopening of assessment u/s 147 - AO having not carried out the scrutiny assessment within the prescribed statutory limit, cannot be given another innings for no fault of the assessee and therefore in the facts and circumstances of the case, ‘reason to believe’ which is the jurisdictional precondition to reopen the assessment as required by the law has not been met in the reasons recorded in the instant case
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